2008-05-28_REVISION - C1981019 - Laserfiche WebLink

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29. Proposed diversity standards for the two post-2008 reclaimed categories appear to be generally appropriate, given the respective land use emphases (grazingland and sagebrush steppe/wildlife habitat). The Division has a couple requests for modification, to ensure that the standards will reflect reclamation plan objectives, and practicable targets based on the seedmixes and practices employed. a) For the grazingland emphasis, please specify that each principle cool season grass to be counted will be a native cool season grass, and that, if five or more native perennial grass taxa contribute between 3% and 50%, the minimum combined relative cover of perennial forbs and shrubs shall be no less than 1%. b) For the wildlife habitat emphasis, please specify that a minimum of two principal native cool season grasses will be established (each between 3% and 50% relative cover). The sentence regarding negatement of the forb/shrub requirement should be deleted, to reflect the importance of life form diversity in the wildlife habitat area. c) For the forb component of the wildlife habitat diversity standard, please consider specification of "at least 4 perennial forbs, each with at least 0.5% relative cover, minimum 3 of which are native; or a total perennial forb component of at least 10% relative cover, at least 5% relative cover of native perennial forbs", to better reflect the emphasis on establishing a diverse, native dominated community. The woody plant requirement will be addressed within the density standard, and does not need to be included in the diversity standard. Colowvo's Response: Part a) Comment noted - corrections to text made as appropriate with the caveat that CDRMS approved introduced plants may count as well (e.g., Orchard Grass or Cicer Milkvetch). Part b) Comment noted - corrections to text made as appropriate with the caveat that CDRMS approved introduced plants may count as well (e.g., Orchard Grass or Cicer Milkvetch). Part c) For the reasons indicated in the response to Comment 428 above, especially with regard to the difficulty in establishing forb populations in a short period of time such as the bond responsibility period, Colowyo respectfully declines the suggested forb release criteria. It has not been Colowyo's experience that the elevated forb levels suggested by the state can be obtained in a consistent manner in a single decade. The closest techniques to those proffered in the TR-72 are the CSU test plots that show variable results (majority offailures) with regard to the suggested criteria. In this regard, the state's suggestions are set too high (not a minimal acceptable criterion) which would then predispose an automatic failure. Colowyo has presented an alternate criterion option that is more achievable in a consistent manner. 30. Under Success Evaluation in Section 4.15.11, on amended page 4.15-31, there is a discussion of the reverse null hypothesis test. Some further elaboration of the reverse null may be warranted, as there are certain particulars that are not fully described in the rule. Specifically, sample adequacy must be achieved in the reference area in order for the one sample test to be used. If sample adequacy is not achieved in the reference area (for cover or production sampling), a two sample reverse null t-test, with Satterthwaite approximated degrees of freedom and standard error can be employed. A minimum sample size of 30 is required in the reference area, as well as the reclaimed area, in this instance. The Division recommends that this clarification be included in the text.